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MCUA Comments on Size Definitions

Missouri Credit Union Association (MCUA) submitted two comment letters to the National Credit Union Administration (NCUA) and the Small Business Administration (SBA) regarding "small entity" and "small business" size definitions. 

MCUA sent a comment letter to NCUA regarding its “small entity” definition that applies to credit unions under NCUA’s regulations.  In the letter, MCUA supports changing the threshold for a “small entity,” and urges NCUA to revise its proposal in several significant ways.  First, for purposes of the Regulatory Flexibility Act (RFA) and similar analyses to assess the impact of a pending proposal, the agency should use the same level that bank regulators use for such determinations.  Under the RFA, the Small Business Administration has currently set the level for “small business” at $175 million and all of the federal financial regulators except for NCUA have adopted that level.  In addition, MCUA believes NCUA should allow credit unions that have no more than $50 million in assets to be eligible for assistance and services from the agency. 

MCUA submitted a comment letter to the Small Business Administration (SBA) regarding its “small business” size standard for credit unions.  MCUA strongly supports SBA’s current review that would raise to $500 million the “small business” size standard for credit unions, which is currently at $175 million.  If adopted, it would permit a greater number of credit unions, though still relatively small, to benefit from provisions that require federal agencies to assess and minimize regulatory costs for smaller entities, including the RFA and the Small Business Regulatory Enforcement Fairness Act (SBREFA), consistent with Executive Orders 13272, 13653, and 13579.  MCUA urged the SBA and the Office of Advocacy to support a substantial increase in the threshold that the National Credit Union Administration (NCUA) uses to define “small entity,” NCUA’s equivalent of “small business.”